IEEPA 关税退款：Amazon 卖家按清关结算日分四类申报

IEEPA tariff refunds are real, they are being paid, and the deciding factor is not how much you imported — it is the liquidation date on each of your customs entries. Entries still open, or liquidated within the last 80 days, are refunded by filing a CAPE declaration in CBP's ACE Portal. Entries liquidated 80 to 180 days ago need a protest. Entries past 180 days currently require a lawsuit at the Court of International Trade. Same duties, same seller, three completely different outcomes. Across the 57 Amazon accounts I managed at Worldfront, duty was the line item sellers understood last and felt first. The ones who will actually collect this money are not those with the biggest import volume — they are the ones who pulled an entry list early, sorted it by liquidation date, and did the one thing each bucket required. This guide is that sort. ## What Are the IEEPA Tariff Refunds? They are refunds of duties collected under tariffs the Supreme Court invalidated. On February 20, 2026 the Court ruled 6–3 in Learning Resources, Inc. v. United States that the International Emergency Economic Powers Act does not authorise the President to impose tariffs of indefinite scope. The orders were revoked, and CBP built a refund system for the money already collected. The mechanics came in two steps sellers routinely conflate. The Supreme Court decided the tariffs were unlawful; it did not order anyone paid. It was the Court of International Trade, on March 4, 2026, that directed CBP to liquidate and where applicable reliquidate entries without the IEEPA duties — and CBP that built CAPE, the Consolidated Administration and Processing of Entries module inside ACE, to process claims at scale. [Update, August 2026: per CBP's August 4 status report, roughly $128.7 billion has entered CAPE for processing and about $100 billion (including statutory interest) has been certified to Treasury for disbursement. The money is flowing — but only to importers who filed. You still have to claim yours.] [One in six submitted entries failed CBP validation. A declaration is not a refund. Budget a second pass for the entries that bounce, and do not spend the money until the ACH lands.] ## Which Tariffs Are Refundable — and Which Are Not Only duties imposed under IEEPA authority are refundable: the fentanyl and trafficking tariffs from February 4, 2025, the reciprocal tariffs from April 5, 2025, and the Venezuela, Brazil, and Russia/India actions — all through February 24, 2026. Everything else on your entry summary, including Section 301 and Section 232, stays exactly where it is. The April version of this post got one thing importantly wrong and it is worth correcting plainly: the reciprocal program was never a flat 35% blanket rate. It was a 10% baseline under Executive Order 14257 effective April 5, 2025, with country-specific rates stacked on top running as high as 50% for 57 trading partners. The 35% figure belongs to the Canada fentanyl tariff from August 1, 2025 — a separate program that is also refundable, and which the original guide left out entirely. One CAPE mechanic follows from that table and catches people out. When a claim processes, ACE recalculates the ordinary duty and every other trade remedy on the entry. You are refunded the IEEPA slice, not the duty line: a Chinese shipment carrying Section 301 plus a 20% IEEPA fentanyl duty gets back the 20 points and keeps the rest. ## The Four-Bucket Liquidation Sort Sort every 2025–2026 entry into one of four buckets by liquidation status, because each bucket has exactly one route and mixing them wastes the only thing that is actually scarce here — time. Unliquidated and recently liquidated entries go through CAPE. Older liquidated entries go through a protest. Finally liquidated entries currently go through court, or nowhere. ## Deadlines: Why This Is Urgent • Entries liquidated more than 180 days ago: no longer an automatic dead end — the July 17, 2026 CIT order opened a Phase 3 reliquidation path, but (per the government) only for importers who filed CIT lawsuits. Deadlines: Feb 4, 2027 (fentanyl tariffs) / Apr 5, 2027 (reciprocal tariffs). Bucket 4 is where the story stopped being administrative and became legal. CAPE Phase 1 opened April 20, 2026 for buckets 1 and 2. Phase 2 opened June 29, 2026 for entries flagged for reconciliation. Phase 3, which would cover finally liquidated entries, is the contested one: DOJ has told the CIT that CBP has no statutory authority to reliquidate outside the 90-day window and that Phase 3 programming will be available only to importers who filed an action at the court. [The Four-Bucket rule: an entry only ever moves in one direction — toward the bucket with fewer options. Every week you wait, some of your bucket-2 entries become bucket-3 entries, and some bucket-3 entries become bucket-4 entries. Nothing ever moves back.] ## Were You Even the Importer of Record? Only the Importer of Record who paid the duties, or the customs broker who filed the entries, can claim through CAPE. Not the buyer, not the brand owner, not whoever actually absorbed the cost. The IOR is the entity named on CBP Form 7501, and for Amazon sellers that answer is less obvious than it should be. ## How Do You Actually File a CAPE Declaration? You file through CBP's ACE Portal, either directly or through your licensed customs broker, after identifying which of your entries carry IEEPA duty lines. The work is 80% identification and 20% filing. Budget several weeks if you do not already have ACE access, because account registration is the step that quietly blows the schedule. 1. Confirm ACE Portal access with an Importer sub-account. If you are starting from zero, register now — practitioners report six to eight weeks for a new ACE account, which is longer than most sellers assume. 2. Enrol in ACH refund. CBP stopped issuing paper checks in February 2026; without ACH on file an approved claim has nowhere to land. 3. Pull the Entry Summary Detail Report (ES-003) in ACE for every entry from February 2025 forward. 4. Filter for Chapter 99 tariff lines — HTSUS codes beginning 9903.01 or 9903.02 — refining by country at the eight-digit level. Those lines are the IEEPA duties; anything else on the entry is not refundable here. 5. Sort the resulting entries into the four buckets by liquidation date. This is the step that determines everything downstream. 6. File a CAPE declaration for buckets 1 and 2. One declaration can carry up to 9,999 entries; split larger lists across multiple filings. Do not file a Post Summary Correction — CBP rejects PSCs as a route to IEEPA refunds. 7. File protests for bucket 3 through your broker, and get counsel's read on bucket 4 before the February and April 2027 CIT deadlines. 8. Track every confirmation number and reconcile refunds against your claim list, because roughly one in six submitted entries fails validation on the first pass. ## What Is the Refund Actually Worth? The duties themselves plus statutory interest under 19 U.S.C. § 1505(c), which accrues from the day you deposited the estimated duties until the entry liquidates or reliquidates. The rate is the IRS overpayment rate, published quarterly — 6% for corporate overpayments in early 2026 — and across the whole pool roughly $650 million of interest is accruing every month. That interest clause is why late filers should still file. On duties deposited in mid-2025 and refunded in late 2026, interest alone can add several percent to the recovery. It is also why the refund is not free money: the duty portion reverses a deduction you already took, and the interest is separately taxable. Both land as ordinary income in the year received. Processing runs 60 to 90 days from acceptance absent compliance issues, though clean entries have come back in weeks. Entries carrying AD/CVD, an open protest, an active drawback claim, or incomplete ACE records take longer. Payment is by ACH to the IOR, or to a properly designated notify party. ## What Are You Paying Now Instead? Less than in 2025, but the relief is narrower than headlines suggest. The Section 122 global 10% surcharge that replaced the IEEPA tariffs on February 24, 2026 expired on July 24, 2026 at the 150-day limit in the Trade Act of 1974. What did not go away: Section 301 on Chinese goods, and Section 232, expanding all year. • Section 232 now reaches steel, aluminium and copper at 50%, 25% or 15% depending on the article, per the April 2, 2026 proclamation, plus autos, parts, and patented pharmaceuticals • Section 301 forced-labor tariffs became effective July 24, 2026 — the same day Section 122 lapsed, which is not a coincidence • Section 338 duties on certain Canadian products at an additional 50% take effect August 19, 2026 ## What to Do This Week Three tasks, in order, and none of them requires a decision about litigation yet. Get the entry list, sort it by liquidation date, and find out who the IOR was. Everything else — CAPE, protest, counsel — follows mechanically from what that sort tells you. 1. Email your customs broker today for every entry from February 2025 forward, with the liquidation date and Chapter 99 duty lines shown. One email — the highest-value hour in this whole process. 2. Sort the list into the four buckets and count the dollars in each. If bucket 4 holds real money, that is your trigger to ask a trade attorney about a protective CIT filing before February 4, 2027. 3. Confirm in writing, per shipment lane, who was named Importer of Record — and if it was a forwarder, open the pass-through conversation before their CAPE declarations go in, not after. 4. File a protective protest on any bucket-3 entry approaching day 180. Many importers are doing this purely to preserve rights while the Phase 3 fight resolves. 5. Keep the entry list, every CAPE confirmation number, and all broker correspondence in one place, and diarise the 60–90 day follow-up per declaration. ## The Bottom Line The IEEPA refund is a one-time recovery on a permanent lesson. Roughly $128.68 billion has been accepted into CAPE and the money is moving — to importers who could produce an entry list and a liquidation date on demand. The question is no longer "did I pay these tariffs" but "which bucket is each entry in, and did I act before it moved." If you take one thing from this guide, take the sort. Four buckets, one email to your broker, an afternoon of work. The sellers who did that in April are being paid now. The ones still meaning to get to it are watching bucket 2 turn into bucket 3, and bucket 3 turn into a lawsuit.